Introduction of deadline to send electronic invoices

Further to our recent update on developments associated with Peru’s e-invoicing system, Peru has introduced further specific obligations in respect of its e-invoicing solution.   

Via Resolution No. 000003-2023, a maximum of three calendar days from the day after invoice issuance has been cited as the maximum timeframe within which to send the electronic invoice to the Peru e-invoicing solution, the SUNAT or to the Electronic Services Operator (OSE).  

Wider tax reforms including proposed B2B e-invoicing and e-reporting

Persistent rumours ran abated in the e-invoicing realm relating to Belgium’s intention to accelerate e-invoicing in the country. We have now been provided with more concrete details about Belgium’s intention to mandate e-invoicing in the country.  

The Belgian Minister of Finance has unveiled more definitive timeframes with regards to anticipated e-invoicing in Belgium.   

The proposed plans point to a hybrid solution including e-invoicing and e-reporting specifically- the latter only just making an appearance in Belgium’s proposed tax reforms. This is likely influenced to a considerable extent by the VAT in the Digital Age (ViDA) proposal, which sets out mandatory cross-border reporting from January 2028 for all EU Member States. You can read more about the proposal here.   

E-invoicing implementation in Belgium is likely to be phased, in line with the following:   

  • 1 January 2024: all large companies are obligated to receive structured invoices   
  • 1 July 2024: e-invoicing will be mandated for taxpayers with an annual turnover of over 9,000,000 Euros   
  • 1 January 2025: taxpayers with an annual turnover of between 700,000 and 9,000,000 Euros will be subject to the new e-invoicing obligations  
  • Other taxpayers will comply at a later unknown date.   

The proposed e-invoicing and e-reporting solution comes as part of wider proposed tax reforms in Belgium, which is also recommending the following VAT rate changes:  

  • A new 9% rate  
  • The broadened application of the 0% VAT rate  
  • This would include ‘essential’ items such as fruits, vegetables, medication, diapers, specific hygiene products, and public transportation  
  • The abolishment of the 12% rate  
  • The existing reduced rates of 6% and 12% would be combined into a new reduced rate of 9%. Coal, considered a major pollutant, would be subject to the standard rate of 21%  
  • The reduction in scope of the reduced 6% VAT rate  
  • The reduced rate of 6% would remain for certain basic utilities like electricity, natural gas, heating, and tap water  
  • More specifically: the VAT rates for demolition and reconstruction specifically are proposed to permanently be set at the new 9% rate, rather than 6%.  

Through suggesting revised VAT rates, Belgium is following in the footsteps of its European counterparts, Switzerland, The Czech Republic and Norway, who are similarly either implementing or contemplating an overhaul of their VAT rates.   

While these changes are substantial, it is important to note that the proposals, including timeframes, are yet in draft form only. Furthermore, the timeframes outlined relate to the e-invoicing element only of the proposal; e-reporting timeframes are yet to be defined.   

Belgium is a compliant territory for Tungsten Network, and we are cognizant of the fact that the anticipated timeframes- commencing on 1 January 2024 for specific companies- are impending.   

Tungsten is closely following developments in Belgium with a firm view as to how we can best support our Belgian market considering any e-invoicing and e-reporting advances.   

National e-Invoice System (KSeF) – consultation conference

With the e-invoicing mandate in Poland gaining ascendancy, the Polish Ministry of Finance held a conference in February 2023 to discuss the upcoming amendments to the draft law introducing mandatory e-invoicing in Poland. The legislative process for this draft law is still ongoing and is expected to be completed in the summer of 2023.  

You can refer to our recent post on the anticipated Polish e-invoicing mandate changes here.   

The above changes have not been enacted yet, but more information on the outcome of the discussion at the conference has been published on the website of the Polish Minister of Finance, with the link directly below:  

https://www.gov.pl/web/finanse/projekt-krajowego-systemu-e-faktur-ksef–konferencja-uzgodnieniowa 

Tungsten is looking forward to clarifying the finalised scope of the e-invoicing requirements in Poland. We will review these once available and consider any resulting impact on our system.   

E-Invoice System will no longer accept 4-digit HSN codes

In accordance with Notification No.78/2020 – Central Tax dated 15th October 2020, taxpayers must provide 6-digit HSN Codes for their outward supplies having AATO(Annual Aggregate Turnover) more than Rs 5 Crores.

The Indian e-Invoice System will not accept 4-digit HSN codes in a few weeks’ time. Taxpayers are advised to adjust their systems to report 6-digit HSN codes to the e-Invoice Portal and comply with the upcoming notification.

Taxpayers may verify all the HSN codes in the ( https://einvoice1.gst.gov.in ) portal under Search->Master->HSN Codes and also test in the sandbox system ( https://einv-apisandbox.nic.in ). It is possible to raise a ticket at Helpdesk in case the 6 digit HSN code is not available.

Updated threshold to comply with the electronic tax invoices

Korean government introduced an electronic tax invoice system (e-Tax) in 2011, which requires businesses to report e-invoices to the government’s platform immediately after issuance. The requirement is being phased out based on businesses’ revenue.   

As of present, taxpayers whose annual revenue exceeds KRW 200 million are required to report e-invoices to the government platform. Starting from 1st July 2023, the threshold will be lowered to KRW 100 million (ca. USD 75 000)  

In accordance with the 2023 tax reform, the threshold for mandatory e-invoices will be lower again from KRW 100 million to KRW 80 million, which will apply to transactions made after July 1, 2024.  

Propose B2B e-invoicing in the 2023/2024 Budget

In the National Budget of Israel 2023/2024, there is mention of introducing a Continuous Transaction Control (CTC) model in the B2B e-invoicing system.   

The tax authority proposes a so called “clearance model”, where invoices must be validated and approved by the government platform before they can be sent to the customers. According to the proposal, the clearance requirements will be applied to all B2B invoices with above NIS 5,000 (c.a USD 1,400) value. Estimates from the Tax Authority suggest that only 15% of invoices are affected.   

Rollout of phase 2 of the Tax Invoice Management System (eTIMS)

Phase 2 of the Tax Invoice Management System (eTIMS) is now live. As part of this phase, different software versions will be launched to facilitate different ways of transmitting electronic invoices in real-time to KRA.  

 The issuing and transmitting of invoices will be available via the following ways :  

  • via the online portal;  
  • via an application on mobile phones;  
  • via an application that shall facilitate integration with the existing billing systems of businesses.  

Move towards mandatory B2G e-invoicing

The Singapore government is making plans to mandate the use of e-invoicing for B2G transactions, according to the speech given on 24th Feb 2023, by Minister of State for Finance and Transport – Hong Tat Chee.   

InvoiceNow is a nationwide E-invoicing method that enables the direct delivery of invoices in a structured digital format on the Peppol network, which will also be the default e-invoice submission channel for all government vendors within the next few years.   

Tungsten provides Peppol invoice services across many of our compliant markets and will follow closely the updates on the Singapore B2G e-invoicing mandate.  

 

Changes on version 2.2 of external specifications for e-invoicing

A new version 2.2 of the Guidelines for mandatory electronic invoicing and reporting has been published by the French authorities. 

The updated version 2.2 includes changes: 

  • Addition of 2 compulsory mentions (single taxable persons) 
  • Detailed review of the factoring management case 
  • Corrections / clarifications in the management cases 
  • Some new business cases (transparent intermediary and Author’s notes) 
  • Clarifications on the management of corrective / rectifying e-reporting flows  
  • Clarifications/further details on the use of APIs  
  • Update of some annexes and in particular the description of the Extensions and their UBL and UN/CEFACT CII mapping (thus also Factur-x).  

The updated version 2.2 is available for download here 

Revised schedule for e-invoicing

Executive Decree No, 3, dated January 2023, has effectively amended Executive Decree No. 25, dated 27 June 2022.  

The amendment has introduced some significant modifications, in particular relating to the timeframe for e-invoicing timeline in Panama. In Panama, taxpayers can opt to use authorised fiscal equipment or process tax invoices through the national e-invoicing system, the Sistema de Facturacion Electronica de Panama (SFEP).  

The amendment confirms that the obligation to use e-invoicing is maintained from 2 January 2023 for the following entities:  

  • Private entities authorized by the Panama Maritime Authority to guarantee compliance with construction, navigation, etc regulations; 
  • Petroleum derivative cargo transportation services; 
  • Hostels with less than 7 rooms; 
  • Leasing real estate under notarized contracts or registered with the Ministry of Housing, by natural or legal persons that manage their own assets. 

 

However, the deadlines for the following entities have been extended: 

  • 1 March 2023 for: 
  • International public passenger transport services by land, air, or sea; and 
  • National public transport services by air; 
  • A phased approach starting from 30 April 2023, 30 June 2023, and 31 August 2023 for operations and services carried out by banks and other financial institutions, including financial leasing companies and investment funds, as well as banking credit, trust, or financial institutions governed by special laws, cooperatives, savings fund institutions, pension funds, retirement and social security funds, and savings and loan entities; and 
  • 31 August 2023 for: 
  • Operations carried out on the stock market; 
  • Operations carried out by the Insurance sector; and 
  • Operations carried out by other financial institutions not specified. 

 

The Ministry of Economy and Finance will separately regulate the phases and procedures for banks and other financial institutions. 

 

From 30 June 2023, invoicing obligations must also be met in respect of operations carried about by companies operating under the following regimes, which has been extended from 1 February 2023: 

  • Baru Free Zone (Zona Franca del Barú); 
  • City of Knowledge (Ciudad del Saber); 
  • Free Zones (Zonas Francas); 
  • Petroleum Free Zone (Zona Libre de Petróleo); 
  • Multinational Enterprises Headquarters Regime (Sede Empresas Multinacionales – SEM); 
  • Panama Pacifico Special Economic Zone (Área Económica Especial Panamá Pacifico – AEEPP); 
  • Colon Free Zone (Zona Libre de Colón – ZLC); and 
  • Multinational Company regime for the provision of services related to Manufacturing (Empresas Multinacionales para la prestación de servicios relacionados con la Manufactura – EMMA), which has been added to schedule. 

 

With respect to the SEM and EMMA regimes, invoicing through SFEP must be implemented considering that companies under these regimes are exempted from using authorised fiscal equipment. Invoicing requirements also apply for any other special zones or regimes that exist or may be created in the future. 

 

Please refer to the Resolution for further information: 

 

Gaceta Oficial Digital (mef.gob.pa) 

Bookkeeping Act update

Last month, we said progress around on the Bookkeeping Act, which aims to digitise accounting records in Denmark, had stalled somewhat due to the introduction of a new government. The Danish Authorities have since issued a new update in respect of the Bookkeeping Act.  

From 1 February 2023, a new schedule for the digital bookkeeping standard came into effect. 

All digital standard systems that need to be registered will need to do so by 1 January 2024.  

We are awaiting more detailed requirements from the Danish government, as well as exact timeframes as to when companies are expected to comply with the Bookkeeping requirements.  

Proposed B2B mandate

In comparison to other countries, Sweden’s intent to drive e-invoicing in the country has been somewhat muted- but this appears to be changing. In light of the VAT in the Digital Age (ViDA) proposal, the next few months is expected to be intriguing period as we await individual country responses to the demands imposed by the proposal. 

The proposal will compel Member States to review their fiscal procedures. The Swedish Agency for Digital Government (DIGG) are now promoting mandatory B2B e-invoicing in Sweden and, in collaboration with the Swedish tax agency has requested that the government delve further into analysing the potential for B2B e-invoicing to commence in the country. 

The timing cannot be considered coincidental, given the recent publication of the proposal. Under current ViDA plans, cross-border e-invoicing will become mandatory in January 2028, and, as a result, Sweden is proposing to review its own domestic e-invoicing framework to ensure that the two are aligned for greater consistency.  

 

Transition period of the third group of taxpayers extended

The Bolivian tax administration (SIN) has released new resolution Nº 102200000025, which extends the transition period of selected taxpayers to implement e-invoicing.

Initially, taxpayers of the third group were expected to be adhere to e-invoicing obligations as of 1 December 2022. However, the resolution extends this to 1 February 2023.

E-invoicing mandate postponement in Poland

The Polish e-invoicing guidelines published at the end of 2022 confirmed a start date of 1 January 2024 for the Polish e-invoicing mandate.

The Polish Ministry of Finance has now confirmed a delay to the commencement of the e-invoicing mandate in Poland, to 1 July 2024.

It appears that there will be changes introduced to the scope of e-invoicing in Poland, including the obligation for exempt taxpayers to use the KSeF e-invoicing platform from 1 January 2025, as well as potential obligations relating to cross-border transactions.

We are expecting further details confirming the scope, alongside other changes, later this year. We will assess the new scope of the mandate, once confirmed, as well as any other changes introduced in the final publication of the changes and will be ready to support the new mandate in line with the revised timeframe of July 2024.

Use and operation of RO e-Transport System

Tungsten has been monitoring the RO e-transport System in Romania. You can read an overview of the System here.

ANAF/AVR joint order no. 1190/4625/2022 has approved the operating rules of the national RO e-Transport System and the categories of road vehicles used for the transport of goods with high fiscal risk that are subject to monitoring. The reporting of data on the road transport of goods with high fiscal risk became mandatory on 1 July 2022.

Inevitably, there will be situations where both goods with high-fiscal risk are transported together with goods not categorised as such. If both goods with a high fiscal risk and other goods are transported within a commercial relationship, all categories of transported goods will be declared in the RO e-Transport System, and the system will generate a single UIT code. In the case of groupage transport, the UIT codes will be noted on the transport documents related to each commercial relationship that includes goods with high fiscal risk.